News and Views for Healthcare Accreditation Professionals

Posts tagged ‘Joint Commission’

I get a lot of questions concerning the ability of nurses to administer agents of deep sedation. I have put together my conclusion based on the following citations from CMS. Be aware that some states have written into the nurse practice act that RNs may not administer agents of deep sedation, or “non-reversable” agents for sedation purposes. My conclusion is, based on the actual CMS COP, that nurses may not administer these agents for the purpose of sedation. Actually, based on CMS, one would wonder if RNs could even MONITOR patients. By the way, supervision of nurses is not even addressed by CMS, so therefore the “supervision” aspect would be irrelevant. Be aware that whether something is Deep Sedation or MAC depends on the manufacturer’s definition of the drug.

482.52 Condition of Participation: Anesthesia Services

Monitored anesthesia care (MAC): anesthesia care that includes the monitoring of the patient by a practitioner who is qualified to administer anesthesia as defined by the regulations at §482.52(a). Indications for MAC depend on the nature of the procedure, the patient’s clinical condition, and/or the potential need to convert to a general or regional anesthetic. Deep sedation/analgesia is included in MAC.

§482.52(a) Standard: Organization and Staffing

Anesthesia must be administered only by —
(1) A qualified anesthesiologist;
(2) A doctor of medicine or osteopathy (other than an anesthesiologist);
(3) A dentist, oral surgeon, or podiatrist who is qualified to administer
anesthesia under State law;
(4) A certified registered nurse anesthetist (CRNA), as defined in §410.69(b) of this chapter, who, unless exempted in accordance with paragraph (c) of this
section, is under the supervision of the operating practitioner or of an anesthesiologist who is immediately available if needed; or
(5) An anesthesiologist’s assistant, as defined in Sec. 410.69(b) of this chapter, who is under the supervision of an anesthesiologist who is immediately available if needed.

Based on the above, it would also appear that Nurse Practitioners or Physician Assistants may also not administer deep sedation.

CMS still holds hospitals to NFPA 99 (4.3.1.2.3(n), 5.4.1.1, and 19.3.2.3) for humidity limits in anesthetizing locations to: 35-60%. The more liberal ANSI recommendation of a lower limit of 20% is NOT CMS approved. Serious findings have been written by CMS when the humidity is out of range and surgery continues.

Addendum: Recently it was made known that Joint Commission will survey the acceptable humidity range as 20%-65%, but caution hospitals that CMS will hold hospitals to the 35%-60% range per NFPA 99.

As the Pyxis serves as “Pharmacy” in L&D, the nurse cannot take the drug from the Pyxis as described and “dispense” it to the physician as this is not in the nurses’ scope of practice per state law, therefore a violation of MM03.01.01 Element 6.